Yes, we believe you may extend a discount on loan interest rates to your officers and directors as well as your employees, and we are not aware of any Illinois laws that would prohibit such a program. As to federal law, Regulation O includes an exception to its requirement that loans to employees be provided on “substantially the same terms” as credit for any other borrower. The exception applies where a bank makes loans under a benefit or compensation program that is (1) widely available to all employees and (2) does not give preference to insiders over other employees. 12 CFR 215.4(a)(2). Because your proposed discount program would be available to all employees, and the same discount would apply to insiders and all other employees, we believe your program would comply with Regulation O.